NY-DFS Proposed Guidance on Character and Fitness (Extension Appeal)
g at xny.io
Thu Jul 20 16:14:27 PDT 2023
On Wed, Jun 28, 2023, 12:04 AM Gunnar Larson <g at xny.io> wrote:
> Ms. Scott:
> NY-DFS recently asked for public comment concerning "Proposed Guidance on
> Assessment of the Character and Fitness of Directors, Senior Officers, and
> Managers" mentioned here:
> xNY.io - Bank.org asks if the NY-DFS will extend deadline for public
> comment to August 5, 2023 from June 30, 2023.
> As requested by NY-DFS, today we provide (in a separate attachment)
> evidence of any documented exceptions to compliance with the "Suggested
> Questions to Facilitate Initial and Ongoing Assessment of Designated
> Persons’ Character and Fitness."
> We have collated 19 references comprising 205 highlights that touch on the
> five key areas below:
> -Harassment and Discrimination Policies
> -Conflict of Interest Policy
> -Insider Trading Policy
> -Records Management Policy
> -Corporate Opportunity Policy
> xNY.io - Bank.org is seeking NY-DFS' extension for public comment to
> August 5, 2023 so that the New York Banking community has time to complete
> Q2-23 earnings call disclosures.
> As documented in the above 19 references, we feel extra time for public
> comment is warranted to ensure that xNY.io - Bank.org did not play a
> significant role or otherwise contribute in a meaningful way to the conduct
> that led to regulatory action or proceeding without ample notice.
> Per point one of NY-DFS' "Suggested Questions to Facilitate Initial and
> Ongoing Assessment of Designated Persons’ Character and Fitness," can you
> kindly acknowledge that you have reviewed and understand our appeal seeking
> extension for public comment to August 5, 2023?
> We hope to hear from you before June 30, 2023 given obvious factors.
> Sending you the very best regards.
> Thank you,
> Gunnar Larson
> xNY.io | Bank.org
> MSc - Digital Currency
> MBA - Entrepreneurship and Innovation (ip)
> G at xNY.io
> New York, New York 10001
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